Health First Colorado Behavioral Health Updates | | |
Welcome to the Health First Colorado Behavioral Health Updates from the Department of Health Care Policy and Financing (HCPF).
Health First Colorado Behavioral Health Updates provides content relevant to the full spectrum of behavioral health services in Colorado. Feel free to share this information with other interested stakeholders!
Feedback, ideas, and questions are welcome and can be shared at hcpf_bhbenefits@state.co.us.
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Behavioral Health Legislative Request for Information Report
HCPF has submitted a report about the utilization of Colorado’s Medicaid behavioral health program in response to a Legislative Request for Information from the Joint Budget Committee. This report includes an overview of the behavioral health services provided in fiscal year (FY) 2023–24 and the performance of the behavioral health managed care entities in calendar year (CY) 2024, as well as highlighting critical changes to the behavioral health Medicaid program between the end of FY 2023-24 and the end of July 2025. The report provides an evaluation of the behavioral health system by measuring member access to care, provider network expansion and contracting timelines, and timeliness of payments to providers.
Read the full Legislative Request for Information.
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New Statewide Funding Opportunities to Address the Opioid Crisis
The Colorado Attorney General’s Office and the Colorado Opioid Abatement Council (COAC) have announced up to $23 million in new statewide opioid abatement funding available through two grant opportunities:
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Round 4 Infrastructure Funding Opportunity – Prioritizes capital or operational investments in rural, underserved, or disproportionately impacted communities, and encourages collaborative or multi-organization proposals.
- Application due January 14, 2026
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Resilient Colorado Grant – Focused on community-based prevention, recovery, and leadership initiatives that strengthen Colorado’s behavioral health and recovery systems.
- Application due December 18, 2025
Please note that funding from these opportunities come from national opioid settlements and must be used for forward looking opioid abatement strategies. Click to see the full list of Approved Uses.
| | FAQs/Clarifications of Coverage and Billing Questions | |
Prior Authorization and Retrospective Reviews for Outpatient Psychotherapy
To meet federal and contractual standards, the Regional Accountable Entities (RAEs) are required to maintain policies and practices to ensure that they are paying for medically necessary psychotherapy services. Based on cost and utilization reviews, and in line with actions taken by the state’s legislature, HCPF has directed the RAEs to develop strategies to address the unmanageable growth in outpatient psychotherapy. This includes an expectation that the RAEs create prior authorization and retroactive review processes looking specifically at outpatient psychotherapy that exceeds 24 sessions in a 12 month period. This applies across all provider types and to any combination of the impacted psychotherapy codes: 90832, 90833, 90834, 90836, 90837, 90838, 90839, 90840, 90846, 90847, 90849, 90853.
The Governor’s Executive Order removed the prohibition on prior authorization review (PAR) of services, restoring it as an option available to the RAEs. However, there is no requirement that utilization management is performed in a specific way. It may be through PAR, but an alternate process such as retrospective review or pending payment may be considered. RAEs will look at their tools to determine what process makes the most sense for their region and will implement unique approaches based on the needs of their networks. If providers are only rendering medically necessary services, they will see no change to their reimbursement.
This policy is necessary to address problematic utilization trends, and avoid service cuts that could limit member access to necessary services.
For questions regarding this policy, please join the Independent Provider Network (IPN) Forum on Friday, December 5, 2025, at 1 p.m. Register via Zoom. Behavioral health policies are available on the Behavioral Health Policies, Standards, and Billing References web page.
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Update on the Health First Colorado Rendering Provider Oversight (RPO) Policy
Thank you to everyone who provided feedback on the draft Supervision Policy for Medicaid Billable Behavioral Health Services, now titled the Rendering Provider Oversight policy for clarity. We’ve published a Summary of Stakeholder Feedback that outlines the input received. Based on one of the most common recommendations, we’re renaming the policy to the Health First Colorado Rendering Provider Oversight (RPO) Policy to better reflect its purpose and scope.
A final draft of the RPO policy was posted on the Behavioral Health Policies, Standards, and Billing References web page on November 13, 2025. The final policy will be posted in early December. Providers with licensed clinicians intending to oversee billing for pre-licensed clinicians and/or unlicensed professionals that fall under the guidelines of this policy must submit this attestation to each contracted RAE by January 1, 2025 to engage in RPO practices outlined by this policy. Organizations, groups, and facilities only need to submit one attestation for their entity; individual attestations for each Rendering Provider are not required.
For questions, please contact hcpf_bhbenefits@state.co.us
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Behavioral Health (BH) Peer Support Professional Certification Requirements: Attestation Required January 1, 2026
In June 2025, the Medicaid Sustainability Memo outlining changes to BH Peer Support was published. The State Medicaid Director letter (SMDL) #07-011 indicates that states must determine the minimum training and certification criteria for BH peer support providers. HCPF is publishing a policy with requirements for Behavioral Health Peer Support Professionals to be certified or in the process of becoming certified in order to deliver billable behavioral health services. Agencies must sign and submit an attestation to their RAE or RAEs by January 1, 2026, attesting to compliance with the updated policy. The attestation will be posted on the Behavioral Health Policies, Standards, and Billing References web page in early December.
Contact hcpf_peerservices@state.co.us with any questions.
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New Frequently Asked Questions (FAQ) on National Correct Coding Initiative (NCCI) edits and Colorado Medically Unlikely Edits (CO MUEs)
The National Correct Coding Initiative (NCCI) edits and Colorado Medically Unlikely Edits (CO MUEs) Frequently Asked Questions (FAQ) have been released. This FAQ includes answers to many of the questions received from providers related to the NCCI and CO MUEs.
Beginning July 1, 2025, HCPF began requiring the RAEs to implement all NCCI edits. NCCI edits and MUEs were created to reduce improper payments stemming from incorrect coding and billing practices. NCCI prevents reimbursement for inappropriate combinations of Current Procedural Terminology (CPT) codes. NCCI edits prevent issues such as add-on codes being billed without a primary procedure code, inappropriate payments when services are reported with an unusually high number of units of service, and code pairs that should not be reported together on the same date of service.
One such code is H0005, Alcohol and/or Drug Services; Group Counseling by a Clinician. This is an encounter code with a unit limit of 1 unit. H0005 can only be billed once a day, regardless of service duration.
Situations where it is medically appropriate or necessary to exceed an NCCI edit or CO MUE may require prior authorization, additional documentation to show medical necessity, or the use of alternative billing codes.
The FAQ and details about CO MUEs and NCCI policy are available on the Behavioral Health Policies, Standards, and Billing References web page. CMS’s NCCI for Medicaid web page has information for all NCCI edits. Contact hcpf_bhbenefits@state.co.us with any additional questions.
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Sunsetting H0006, Alcohol and/or Drug Service - Case Management
HCPF is sunsetting procedure code H0006, Alcohol and/or Drug Service - Case Management, effective December 31, 2025, and will no longer reimburse for this procedure code. The services covered under this substance use disorder (SUD) specific code are able to be delivered more generally under other existing behavioral health case management codes. Please refer to the State Behavioral Health Services Billing Manual for other case management procedure codes.
Contact hcpf_bhbenefits@state.co.us with any additional questions.
| | Other Things Happening in Behavioral Health | |
Colorado System of Care (CO-SOC) Updates
HCPF is excited to announce that the Colorado System of Care (CO-SOC) is officially serving Members. CO-SOC is the statewide framework developed collaboratively by HCPF and the Behavioral Health Administration (BHA) to support children and youth with complex or high-acuity behavioral health needs.
HCPF has been working closely with the RAEs, Qualified Residential Treatment Programs (QRTPs), Psychiatric Residential Treatment Facilities (PRTFs), CO-SOC providers, and other stakeholders to ensure Members are receiving the highest quality of care within CO-SOC.
Visit the CO-SOC web page for more information and to sign up for the newsletter.
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Certified Community Behavioral Health Clinics (CCBHC) Planning Grant Updates
CCBHC Planning Grant Year-End Updates:
The 2025 calendar year is coming to an end along with the grant timeline for the Colorado 2025 Certified Community Behavioral Health Clinics (CCBHC) Planning Grant. CCBHC Planning Grant team members from both HCPF and BHA are working to finalize required activities and objectives.
Reminders for end-of-year CCBHC communications and stakeholder engagement:
- December workgroup meetings and public forums have been cancelled due to increased scheduling conflicts.
- The next CCBHC Steering Committee meeting will take place on January 26, 2026, from 3 p.m. to 4 p.m. Register through Zoom or on the CCBHC Planning Grant web page.
CCBHC Planning Grant No-Cost Extension Request
The joint state agency team has also submitted a request for a CCBHC Planning Grant No-Cost Extension (NCE). If granted, the NCE would allow federal resources to continue into 2026, supporting ongoing efforts of CCBHC work in Colorado. Decisions on NCE requests are anticipated by December 30, 2025.
CCBHC Planning Grant Memorandums
Please continue to check the Behavioral Health Administration Memorandum Web page for updated memorandums and communications regarding planned policies and infrastructure for CCBHC services in Colorado. CCBHC Memorandum #2 is now available for review. This memo highlights certification details, known and anticipated certification timelines, and provides access to the Provider Readiness Assessment.
For additional details and reference materials, providers and stakeholders are encouraged to explore the CCBHC Planning Grant Webpage.
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Behavioral Health Provider Engagement Opportunities
NEW! Behavioral Health Hospital & Residential Facilities Office Hours.
We are pleased to announce the launch of Behavioral Health Hospital & Residential Facility (BHHRF) Office Hours, beginning on February 20th, 2026. The BHHRF Office Hours will be held monthly on the third Thursday from 12 p.m. to 1 p.m., except during months when the BHHRF Forum is scheduled. These office hour sessions are designed to support ongoing collaboration, communication, and engagement with our partners.
- February 20, 2026, from 12 p.m. to 1 p.m. Register in advance.
Please note that the January 15, 2026, BHHRF Forum will also take place as scheduled.
- January 15, 2026, from 12 p.m. to 1 p.m. Register in advance.
Thank you for your continued participation and commitment to strengthening behavioral health services across Colorado.
Behavioral health providers are encouraged to participate in provider forums, meetings, and office hours. Below are a series of ongoing opportunities available. Many of these sessions require registration to allow for planning based on attendance and to prepare responses and presentations designed to address questions often submitted in advance.
View the full calendar of events on the Behavioral Health Initiatives and Coverage Office webpage.
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Forums: Designed to be a space for presentation of information and discussion:
- Behavioral Health Hospital & Residential Facility Forum. Quarterly (First month of the quarter) on the third Thursday from 12 p.m. to 1 p.m. Register in advance.
- Independent Provider Network (IPN) Forum. Quarterly on the first Friday from 1 p.m. to 2 p.m. Register in advance. (June, September, and December)
- SUD Forum. Quarterly (first month of the quarter) on the first Wednesday from 2 p.m. to 3 p.m. Register in advance.
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Office Hours and Technical Assistance: Designed to be a “drop in” space for quick answers to issues best addressed by a brief discussion:
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NEW: Behavioral Health Hospital & Residential Facility Office Hours. Monthly on the third Thursday from 12 p.m. to 1 p.m. Register in advance.
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UPDATED DATE: Independent Provider Network (IPN) Office Hours. Monthly on the first Friday of the month from 1 p.m. to 2 p.m. Register in advance.
- Safety Net and Crisis Office Hours. Monthly on the second Tuesday from 12 p.m. to 1 p.m. Register in advance.
- Supportive Housing Provider Office Hours. Monthly on the last Thursday from 2 p.m. to 3 p.m. Register in advance.
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UPDATED TIME: Peer Support Office Hours. Monthly on the fourth Thursday from 11:30 a.m. to 12:30 p.m. Register in advance.
- SUD Provider Office Hours. Monthly on the first Wednesday from 2 p.m. to 3 p.m. Register in advance.
Email hcpf_bhbenefits@state.co.us to share feedback, ideas, and questions with HCPF.
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